How DGFT and CPCB Work Together for Extended Producer Responsibility (EPR) Imports

Introduction — The Real Story Behind Delayed Imports

Imagine you’ve finalized a shipment of lithium batteries from China. The invoice is cleared, payment sent, and you hold a valid DGFT import license.
But at the port, the Customs officer asks for a CPCB EPR registration number — something you didn’t know you needed. The shipment gets stuck, and every passing day adds demurrage charges.

This situation is becoming common for OEMs, distributors, and traders.
The reason? Two different regulators — DGFT and CPCB — now operate in sync under India’s EPR ecosystem.

This blog decodes how both systems interact and why aligning them early can save weeks of delay and lakhs in penalties.

Understanding the Two Pillars of EPR Imports

Extended Producer Responsibility (EPR) is not just about recycling — it’s about accountability across the product life cycle.

• DGFT (Directorate General of Foreign Trade) controls what can enter India. It issues import licenses for restricted or conditionally allowed products such as batteries, solar modules, plastics, and electronic waste.
• CPCB (Central Pollution Control Board) ensures what happens after those products enter — that importers and producers collect, recycle, or responsibly dispose of them.

Together, they form the foundation of India’s compliance chain for sustainable trade.

Think of DGFT as the “entry gate” and CPCB as the “exit gate.” Both must open smoothly for a compliant import journey.

Why Businesses Can’t Ignore the EPR Layer

Many importers assume that EPR rules apply only to Indian manufacturers. However, as per BWM (2022), E-Waste Rules (2022), and PWM (2022) amendments, importers are treated as “producers.”

That means:

• You are responsible for the lifecycle of imported goods.
• You must register on the CPCB EPR Portal before the first import.
• Customs can hold your consignment if your EPR registration is pending.

This shift is part of India’s circular economy policy — encouraging companies to design for reuse, recycling, and traceability.

How DGFT and CPCB Collaborate Under the EPR Framework

DGFT and CPCB operate under two ministries (Commerce and Environment), but now share digital data points through Customs ICEGATE and the National Single Window portal.

Here’s how their workflows overlap:

• DGFT Import Authorization: Captures the importer’s IEC and restricted product code.
• CPCB EPR Portal: Stores the same IEC under producer/importer registration.
• Customs Verification: Cross-checks both records before clearing the Bill of Entry.

This integration was strengthened after CPCB’s 2023 circular directing Customs and CBIC to verify EPR registration numbers at ports.
Thus, DGFT and CPCB now function as compliance partners ensuring no environmentally sensitive product bypasses accountability.

Step-by-Step Coordination for EPR-Compliant Imports

To simplify your compliance journey, here’s how importers can align both approvals efficiently:

• Identify if your product is restricted under DGFT ITC (HS) Schedule.
• Obtain Import Authorization on DGFT portal using your IEC.
• Check the relevant EPR category — Battery, Plastic, or E-Waste.
• File EPR registration on the CPCB portal with business documents and proposed collection plan.
• Link your IEC, PAN, and GST details consistently across both applications.
• Once both approvals are received, submit your EPR certificate number to Customs.

Each stage complements the next — skipping one can lead to automatic hold or rejection.

1 — Timeline Comparison

Authority	Process	Average Approval Time	Validity	Renewal Period
DGFT	Import License (Restricted Items)	4–6 weeks	12 months	Apply 6 months before expiry
CPCB	EPR Registration	30–40 working days	5 years	Apply 90 days before expiry

Insight: DGFT licenses are short-term trade approvals, while CPCB registration creates long-term compliance continuity. Smart importers synchronize both to avoid gaps.

2 — Post-Import Responsibilities

EPR Category	Key Duty	Return Filing Deadline	Penalty / Risk
Battery Waste	Collect, store, and recycle imported batteries	30 Sept each FY	Environmental Compensation (EC)
E-Waste	Channelize waste electronics to CPCB-registered recyclers	30 June each FY	Suspension or de-registration
Plastic Packaging	Recycle or reuse mandated % of packaging	30 June each FY	Monetary fine under PWM Rules

Interpretation: Each rule has a unique compliance calendar. Importers managing multiple product categories must track all reporting windows.

Common Mistakes Importers Should Avoid

Even well-prepared businesses make preventable errors.
Here are the top compliance gaps we find at Green Permits:

• Applying for DGFT import license without CPCB registration proof.
• Using inconsistent company names or IEC details across portals.
• Missing the annual return deadline (30 June or 30 Sept).
• Failing to renew registration before expiry.
• Not linking recycling partners or agreements on CPCB portal.

Avoiding these saves both time and customs penalties.

What Happens When EPR Numbers Don’t Match at Customs

Since 2024, CPCB’s circular requires Customs to verify every EPR number for import consignments under notified categories.

If details don’t match:

• The shipment gets red-flagged in ICEGATE.
• Importer receives an Environment Ministry notice.
• Clearance resumes only after registration validation — often taking 10–15 days.

Lesson: Linking your DGFT and CPCB details before shipment saves weeks of operational delay.

Financial Impact of Delayed Compliance

Let’s consider a typical importer scenario:

• Daily demurrage cost: ₹15,000–₹25,000
• CPCB penalty (if non-compliant): ₹1–2 lakh per violation
• Lost production or market delay: 10–15 days

By contrast, the cost of proactive registration and annual filing is minimal — often under ₹30,000 a year.
That’s why early compliance isn’t just safe — it’s profitable.

How Green Permits Simplifies DGFT + CPCB Compliance

At Green Permits, we handle every stage for you:

• Assess if your product falls under restricted or EPR-controlled categories.
• File both DGFT license and CPCB registration simultaneously.
• Draft your recycling or take-back plan as per latest CPCB templates.
• Coordinate follow-ups until approval and license issue.
• Manage EPR returns and renewals annually to keep you audit-ready.

Our clients — from electronics importers to solar OEMs — have reduced approval time by 40–60% through our integrated compliance process.

Internal Links:
EPR Authorization | BIS Certification | Recycling Plant Setup

Key Takeaways for Importers

• Always verify if your product needs DGFT import authorization and CPCB registration.
• Use same business credentials across both systems (IEC, PAN, GST).
• Schedule renewals proactively to avoid lapses.
• Maintain quarterly compliance checks.
• Partner with experts to handle documentation and submissions.

Compliance is no longer a bureaucratic hurdle — it’s a business continuity tool.

Conclusion — Turning Compliance into a Competitive Edge

When DGFT and CPCB frameworks are aligned, importers gain speed, credibility, and confidence.
Early registration removes uncertainty at ports, builds trust with partners, and proves your brand’s environmental responsibility.

Green Permits ensures that your business stays compliant, certified, and ready for growth — every single shipment.

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